ML20202C975
| ML20202C975 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/27/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20202C973 | List: |
| References | |
| NUDOCS 9902010225 | |
| Download: ML20202C975 (4) | |
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UNITE 3 STATES i
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30006 0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.102 TO FACILITY OPERATING LICENSE NO. NPF-47 l
l-ENTERGY OPERATIONS. INC.
RIVER BEND STATION. UNIT 1 1
L DOCKET NO. 50-458
1.0 INTRODUCTION
By application dated September 22,1998, Entergy Operations, Inc. (the licensee) requested
. changes to the License Conditions (Facility Operating License No. NPF-47) for the River Bend l
Station (RBS), Unit 1. The proposed changes would remove License Condition 2.C.(8),
"[Transamerica Delaval, incorporated] TDI Diesel Engines," and Attachment 3 to NPF-47, "TDI Diesel Engines Requirements."
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In the September 22,1998, application, the licensee cited as its bases for removing the j.
aforementioned licensing conditions the findings and conclusions of the NRC-approved version of the Transamerica Deleval, Inc. Emergen..y Diesel Generators Owners Group Generic L
Topical Report TDI EDG-001-A as submittod on April 28,1994, and NRC Safety Evaluation L
Report (SER), " Operability and Reliability Review of Emergency Diesel Generators L
Manufactured by Transamerica Delaval, Inc." dated March 17,1994.
The licensee also requested clarification of a statement made on page 9, paragraph 5 of the March 17,1994, SER. The SER stated that all members of the TDI Owners' Group are l
committed to implement changes to EDG control system to permit slow starts. The licensee maintained in the amendment request that RBS does not believe that implementation of this commitment is now necessary, and further declared that their experience has shown that fast starts have "not adversely affected engine performance or resulted in excessive or rapid engine l~
wear when proper prelubrication procedures are ut ;1 prior to planned engine starts."
2.0 BACKGROUND
License Condition 2.C.(8) and Attachment 3 to NPF-47 currently prescribe inspection requirements in the event of specific overload conditions experienced by the Division I and L-Division ll emergency diesel generators (EDGs), and were imposed in response to the issues i
discussed in Supplement 3 to the River Bend Station Operating License Safety Evaluation Report, NUREG-0989, and in NUREG-1216, " Safety Evaluation Report Related to the
. Operability and Reliability of Emergency Diesel Generators Manufactured by Transamerica 4
4 Delaval, Inc.," dated August 1986. These issues have been resolved as stated below and, accordingly, these license conditions are no longer warranted and may be deleted.
i 03oh58 PDR-A
2 3.0 EVALUATION The TDI diesel generators Owners' Group (Owners' Group) submitted proposals on November 30,1992, and December 7,1993, on behalf of a number of plants with TDI emergency diesel generators (EDGs) including the River Bend plant. The Owners' Group proposed removal of diesel generator related licensing conditions. These conditions were imposed as part of a technical resolution to address concerns regarding the reliability of the TDI EDGs following the crankshaft failure at Shoreham in August 1983. The technical resolution involved implementation of Phase I and Phase ll programs as identified in NUREG-1216. The Phase i program focused on the resolution of known engine component problems that had potential generic implications, while the Phase 11 program focused on the design review of a large set of important engine components to ensure their adequacy from a manufacturing standpoint, as well as operational performance. At that time, the staff concluded that these components merited special emphasis in the area of load restrictions and/or maintenance and surveillance. The 16 major components which were identified included connecting rods, crankshafts, cylinder blocks, cylinder heads, piston skirts, and turbochargers. Engine load restrictions were addressed in the plant specific, license conditions, engine operating procedures and operator training, as appropriate, for five of these components. The most critical periodic maintenance / surveillance actions for these components were incorporated as license conditions.
On the basis of substantial operational data and inspection results, the Owners' Group provided information in its submittals of November 1992 and December 1993 to demonstrate that the special concerns of NUREG-1216 were no longer warranted. The Owners' Group stated that the TDI EDGs should be treated on a par with other EDGs within the nuclear industry and subjected to the same standard regulations, without the special requirements of NUREG-1216.
In addition, the Owners' Group stated that this action willimprove availability of the engines for service, especially during outages, while maintaining current reliability levels.
Between 1993 - 1994, the Nuclear Regulatory Commission (NRC) staff and its consultants at Pacific Northwest Laboratories completed a review of the operational data and inspection results contained in the Owners' Group submittals relative to the individual components. In addition, independent opinions were obtained from three leading diesel engine experts regarding these inspection requirements. On the basis of the review, the staff concluded that there was adequate justification for removing the present component-based licensing conditions. The staff's evaluation of the Owners' Group submittals was reported in a letter to Mr. R. C. Day, TDI Diesel Generators Owners' Group Clearinghouse, dated March 17,1994.'
The NRC staff has reviewed the licensee's submittal of September 22,1998, with respect to whether its findings from its review of the Owners' Group submittals are applicable to the River Bend Station. Appendix D of the Safety Evaluation of the Owners' Group submittals identifies the specific license condition components that may be deleted as a result cf the review. These components encompass and are consistent with the conditions in the RBS operating licenses.
' Letter from Mr. James A. Norberg, NRC, to Mr. R. C. Day, Duke Engineering and Services, Inc., TDI Diesel Generators Owners' Group Cleari ghouse, dated March 17,1994.
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. Therefore, the NRC staff concludes that the licensee's proposalis consistent with its Safety Evaluation on the Owners' Group submittals and that License Condition 2.C.(8) and the related i to Facility Operating License NPF-47 may be deleted.
EDG Slow Start Controls in its September 22,1998, amendment request, the licensee also requested clarification of a statement made on page 9, paragraph 5, of the March 17,1994, SER approving the TDI Owners' Group Generic Topical Report. In the SER, the NRC stated that all members of the owners' group were committed to implementing EDG control system changes to permit slow starts. The intent of implementing these changes was to improve TDI engine components' life expectancy by minimizing fast starts under " cold" conditions. Experience has shown that component life expectancy in commercial TDI engines which are not subject to fast starts is far greater than life expectancy for TDI components in nuclear service. It was expected that owners' group members would implement changes to EDG control systems to permit slow engine starts in order to minimize engine wear and tear, thus improving engine reliability.
The licensee maintains in its September 22,1998, amendment request that its experience has been that " fast starts have not adversely affected engine performance or rapid engine wear when proper pre-lubrication procedures are used prior to planned engine starts." RBS operating procedures require pre-lubrication of the diesel with the pre-lube oil pump immediately prior to an engine start. RBS maintenance experience has shown "very low" wear rates on internal engine components and turbocharger thrust bearings. The staff agrees that the engine pre-lubrication controls provided for in RBS operating procedures meets the intent of the Owners' Group commitment to install EDG controls to permit slow starts as referenc2d in the March 17,1994, SER. The staff's concurrence is also based upon existing regulatory requirements, described below, which provide further assurance that the EDGs will continue to be maintained in manner that appropriately balances reliability and availability:
1.
Paragraph (a)(1) of 10 CFR 50.65, " Requirements for monitoring the effectimess of maintenance at nuclear power plants," states that:
Each holder of a license to operate a nuclear power plant under s950.21(b) or 50.22 shall monitor the performance or condition of structures, systems, or components, against Ibensee-established goals, in a manner sufficient to pro;lde reasonable assurance that such structures, systems, and components, as defined in paragraph (b), are capable of fulfilling their Intended functions. Such goals shall be established commensurate with safety and, where practical, take into account industry-wide opbratirig experience. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken. [ Emphasis added)
Additionally, Paragraph (3) of 650.65 states that:
Performance and condition monHoririg activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the intervalbetween evaluations does not exceed 24 months. The evaluations shallbe conducted taking into account, where practical, industry-wide operating experience.
Adjustments shallbe made where necessary to ensure thM the objective of preventing failures of structures, systems, and componews through maintenance is appropriately balanced against the objective of minimizing unavailability of
o i l l
structures, systems, and components due to monitoring orpreventive maintenance. In performing monitoring andpreventive maintenance activities, an assessment of the total plant equipment that is out of service should be taken into account to determine the overall i
eWect on performance of safety functions. \\ Emphasis added) 2.
RBS stated that it will continue to perform routine inspections in accordance with 4
the vendor's preventive maintenance recommendations, which currently includes periodic engine tear-downs, per Technical Requirements Manual (TRM) l surveillance TSR 3.8.1.21. Potential changes to the current program will require the licensee to perform an evaluation in accordance with 10 CFR 50.59.
Since 10 CFR 50.65(b)(1) obliges the licensee to include their safety-related EDGs within the scope of the Maintenance Rule, RBS is required to establish a preventive maintenance program which properly balances EDG reliability and availability. The staff expects licensees to monitor and compare sub-component wear and tear of major safety-related equipment, such as emergency diesel generators, vis-a-vis other comparable equipment within and outside the nuclear industry to ensure its preventive maintenance program is effective. As a result, the staff believes there is sufficient regulatory oversight and programs to ensure that the licensee's current practice of implementing pre-lubrication controls in lieu of slow start controls will result in satisfactory equipment and sub-component reliability.
4.0 STATE CONSULTATION
l In accordance with the Commission's regulations, the Louisiana State Official was notified of i
the proposed issuance of the amendment. The State official had no comments.
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5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 Cl;R Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The l
Commission has previously issued a proposed finding that the amendment involves no l
significant hazards consideration, and there has been no public comment on such finding i
(63 FR 59592). Accordingly, the amendment meets the eligibility criteria for categorical i
exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prograd in connection with the l
issuance of the amendment.
6.0 CONCLUSION
i The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the l
Commission's regulations, and (3) the issuance of the amendment will not be inimical to the l
common defense and security or to the health and safety of the public.
Principal Contributor: R. J. Fretz 5
l Date: January 27, 1999 f
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